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The policy discloses that Amplitude's session replay technology is deployed to record user sessions and collect browsing activity over time and across different websites, with a stated commitment to provide notice and seek consent before recording sessions that may include personal information.
This analysis describes what Ideogram's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes that Ideogram deploys cross-site behavioral tracking and session recording technology. The policy states that consent will be sought before collecting personal information within session recordings, though the scope and mechanism of this consent process are not fully specified in the document.
Interpretive note: The policy states consent will be sought before capturing personal information in session recordings, but does not specify the mechanism, timing, or granularity of this consent process, creating uncertainty about operational implementation.
The updated policy now provides explicit disclosure of which categories of personal information are collected and which parties receive each category. Previously, the policy required readers to consult other sections to identify this information. The updated table format discloses that identifiers such as name and email address, visual information including uploaded images, and geolocation data may be shared with other users, vendors, service providers, login integration partners, social media widgets, and affiliates. This change provides clearer visibility into data sharing practices without altering what data is collected or shared, but rather how that information is disclosed.
View change record →The updated policy no longer provides a single consolidated view of which specific categories of recipients receive which types of personal data. Previously, users could see in one table that identifiers, commercial information, geolocation data, images, account credentials, and precise location were shared with specific recipient categories such as vendors, service providers, other users, login partners, social media widgets, and tracking technology providers. The revised policy instead directs users to review other sections of the document to find this information. The specificity and accessibility of this disclosure has been reduced, though the underlying data-sharing practices may remain unchanged.
View change record →Under this provision, Ideogram's platform records user sessions and browisng activity across different websites using Amplitude's technology. The agreement states that notice and consent will be provided before personal information is captured in session recordings, and users may block or delete tracking technologies through browser settings, though doing so may affect platform functionality.
Cross-platform context
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"We use Tracking Technologies, including Google Analytics and Amplitude's session replay technology, to collect information about your browsing activities, including session recordings and information about your browsing over time and across different websites following your use of our Services. Additionally, we will provide notice and ask for your consent before collecting any personal information that may be included in a session recording.Excerpt from Ideogram's Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates the GDPR ePrivacy Directive, EU and UK cookie consent requirements, CCPA disclosure obligations for the use of third-party tracking technologies, and potentially applicable U.S. state wiretapping or electronic communications statutes, including the California Invasion of Privacy Act (CIPA), which has been the basis of litigation regarding session replay technology. The FTC and state attorneys general are relevant enforcement authorities. 2) GOVERNANCE EXPOSURE: High. Session replay technology has been the subject of regulatory scrutiny and civil litigation in California and other jurisdictions, with courts and regulators examining whether such recording constitutes interception of electronic communications. The policy's acknowledgment that consent will be sought before capturing personal information in session recordings suggests awareness of this exposure, but the mechanism and sufficiency of that consent process are not specified in this document. 3) JURISDICTION FLAGS: California users face heightened exposure given CIPA's application to electronic communications interception. EU and UK users are subject to ePrivacy Directive requirements for consent prior to non-essential cookie and tracking technology deployment. Illinois and other states with electronic surveillance statutes should also be evaluated. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement and vendor assessment teams should verify the terms under which Amplitude processes session recording data, the data retention practices Amplitude applies to this data, and whether the Ideogram-Amplitude relationship is structured as a data processor agreement consistent with GDPR Article 28 or equivalent. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit the consent mechanism described in this provision to confirm it is operationally implemented, assess whether the cross-site tracking disclosure is sufficient under CCPA and GDPR transparency standards, and evaluate whether the session replay deployment requires a data protection impact assessment (DPIA) under GDPR Article 35.
This provision establishes that Ideogram deploys cross-site behavioral tracking and session recording technology. The policy states that consent will be sought before collecting personal information within session recordings, though the scope and mechanism of this consent process are not fully specified in the document.
Under this provision, Ideogram's platform records user sessions and browisng activity across different websites using Amplitude's technology. The agreement states that notice and consent will be provided before personal information is captured in session recordings, and users may block or delete tracking technologies through browser settings, though doing so may affect platform functionality.
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